Criminal Appeals And Post-Conviction Reviews
1. Overview: Criminal Appeals and Post-Conviction Reviews
A. Criminal Appeals
A criminal appeal is a process by which a convicted person challenges the trial court’s decision in a higher court. It focuses on errors of law, procedural mistakes, or evidentiary issues during the trial.
Purpose: To ensure justice and correct errors made in trial proceedings.
Types of appeals:
Conviction appeal: Challenging the guilty verdict.
Sentence appeal: Challenging the punishment imposed.
Appellate courts do not re-try facts; they examine the record for legal errors.
B. Post-Conviction Review
Post-conviction review occurs after all normal appeals are exhausted. It is often based on constitutional grounds such as ineffective assistance of counsel, newly discovered evidence, or violation of rights.
In the U.S., this is commonly through:
Habeas corpus petitions (federal or state)
State post-conviction relief petitions
Key distinction: Unlike appeals, post-conviction reviews may introduce new evidence or address issues not raised on direct appeal.
2. Detailed Cases in Criminal Appeals and Post-Conviction
Case 1: Gideon v. Wainwright, 372 U.S. 335 (1963)
Facts: Clarence Gideon was charged with felony theft in Florida. He could not afford an attorney and requested the court to appoint one. The court denied him, and he was convicted.
Legal Issue: Does the Sixth Amendment guarantee the right to counsel for criminal defendants in state courts?
Outcome: Supreme Court ruled unanimously in favor of Gideon, establishing that the right to counsel is fundamental in criminal cases.
Significance:
Gideon’s conviction was overturned.
Established right to post-conviction relief based on constitutional violation.
Key precedent for appeals and post-conviction claims involving ineffective assistance of counsel.
Case 2: Brady v. Maryland, 373 U.S. 83 (1963)
Facts: John Brady was convicted of murder. During the trial, the prosecution withheld a statement that a co-defendant had confessed.
Legal Issue: Does suppression of evidence by the prosecution violate due process?
Outcome: Supreme Court held that suppression of exculpatory evidence by the prosecution violates the defendant's right to due process.
Significance:
Created the “Brady Rule”: the prosecution must disclose all evidence favorable to the accused.
Frequently grounds for post-conviction relief if such evidence surfaces later.
Case 3: Strickland v. Washington, 466 U.S. 668 (1984)
Facts: David Washington was convicted of murder. He claimed his trial attorney was ineffective and did not adequately prepare or present key evidence.
Legal Issue: What standard applies to claims of ineffective assistance of counsel?
Outcome: Supreme Court established a two-pronged test:
Performance Prong: Counsel’s performance was deficient.
Prejudice Prong: The deficient performance affected the outcome.
Significance:
Provides the standard for post-conviction relief claims based on ineffective counsel.
Widely cited in appeals and habeas corpus petitions.
Case 4: Miranda v. Arizona, 384 U.S. 436 (1966)
Facts: Ernesto Miranda was arrested and confessed without being informed of his right to remain silent or have an attorney.
Legal Issue: Must suspects be informed of their constitutional rights before custodial interrogation?
Outcome: Supreme Court ruled that failure to provide Miranda warnings violates the Fifth Amendment.
Significance:
Established the Miranda Rule.
Grounds for appeal or post-conviction relief if confessions were obtained unlawfully.
Case 5: Schlup v. Delo, 513 U.S. 298 (1995)
Facts: Schlup claimed actual innocence based on new evidence discovered after his conviction.
Legal Issue: Can a claim of actual innocence allow a court to review a procedurally defaulted habeas petition?
Outcome: Supreme Court ruled that a credible claim of actual innocence allows a federal court to consider otherwise barred claims.
Significance:
Strengthened the post-conviction review system.
Protects against wrongful convictions when new evidence emerges.
Case 6: McCleskey v. Kemp, 481 U.S. 279 (1987)
Facts: Warren McCleskey, an African American, was sentenced to death in Georgia. He argued racial bias influenced his sentence.
Legal Issue: Does statistical evidence of racial discrimination justify overturning a death sentence?
Outcome: Supreme Court rejected his appeal.
Significance:
Highlights limits of appeals and post-conviction relief based on systemic biases.
Shows courts require specific proof of discrimination in individual cases.
3. Key Takeaways
Appeals focus on errors during trial; post-conviction review often addresses constitutional violations or new evidence.
Significant case law shapes these processes:
Right to counsel → Gideon v. Wainwright
Evidence disclosure → Brady v. Maryland
Ineffective counsel → Strickland v. Washington
Rights during interrogation → Miranda v. Arizona
Actual innocence → Schlup v. Delo
Limits of systemic bias claims → McCleskey v. Kemp
Post-conviction remedies may include:
New trial
Sentence reduction
Overturning conviction
Habeas corpus relief
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